The Industrial Carbon Management Strategy. What is good and where does it disappoint?

The European Commission’s first ever strategy governing carbon capture, utilisation and storage (CCUS) – the Industrial Carbon Management Strategy – is an important step for the deployment of CCS in Europe. For Romania and Central and Eastern Europe (CEE), with potentially significant carbon storage capacity and important industries that will need to capture their emissions, this long-awaited Strategy sets a strategic direction which should enable firmer and quicker action on making CCUS a reality, and enabling a fair geographical spread of new technologies and infrastructure across a currently West-centric Europe.   


Luciana Miu – EPG Head of Clean Economy:

The Strategy does well to broach the subject of actual climate benefits of CCUS projects, including a focus on “process emissions” in the decade to 2030 and a chapter on the removal of atmospheric and biogenic CO2. However, the incoming Commission can be bolder in differentiating climate-positive use cases of CCUS, particularly given the vague language around capturing CO2 in the power sector in the EU’s 2040 climate target.  While restrictive lists of eligible capture sites may be counterproductive, there is really no such thing as “clean carbon”, and facilities should be required to conduct a thorough assessment of their technological options for reaching a clear emissions target, before requesting public funding for carbon capture. 

Importantly, the Strategy also addresses the issues of CO2 transport, a key part of the CCUS value chain, and we hope to soon see an associated dedicated regulatory package on this complex issue, as indicated in the Strategy. Funding will also be available, with a call forthcoming for cross-border CO2 transport infrastructure under the Connecting Europe Facility. This is a good opportunity for CEE countries to plan regional CO2 transport, developing storage hubs in the eastern Mediterranean Sea and Black Sea areas to balance the North Sea-focused CCS landscape in Europe. The commitment to develop minimum standards for CO2 streams is also welcome. 

For an efficient decarbonisation of EU industries, it is vital that CCUS projects demonstrate climate benefits in line with emissions targets. Carbon capture and utilisation (CCU) pathways which do not allow for carbon recycling (including e-fuels and Enhanced Hydrocarbon Recovery) should be subject to rigorous accounting to avoid unnecessary sunk costs and greenwashing. The Strategy’s promise to start addressing these issues in the 2026 EU ETS revision may not be enough to firmly direct EU CCUS sector towards projects with durable climate benefits. Indeed, this is the original remit of the CCUS Observatory, a watchdog project proposed by EPG and now being piloted by the European Commission. 

It is disappointing to see the ever-neglected issue of public perception of CCUS only briefly addressed in the Strategy. As co-chair of the CCUS Forum’s Working Group on public perception of CCUS, EPG heard consistently from a wide range of stakeholders about the importance of considering public perception, particularly at community level, and engaging in earnest public dialogue for upcoming projects. The lack of a clear mandate for project developers to conduct transparent public engagement is a missed opportunity. It risks leading to a fragmented approach in aligning CCUS project deployment with social needs and concerns, and ensuring that CCUS is part of a Just Transition.”  

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